HMRC Opens the Worldwide Disclosure Facility

On September 5, HMRC opened the Worldwide Disclosure Facility allowing multinationals to disclose a UK tax liability that relates wholly or in part to an offshore issue. On September 6, HMRC followed with a guidance to tax avoidance elaborating on how to get help to settle the tax affairs.


On 31 December 2015 all HM Revenue and Customs (HMRC) offshore facilities closed. HMRC informs that it reopened the Worldwide Disclosure Facility (WDF) to provide a final chance for multinationals to disclose a UK tax liability before CRS comes into effect.

Tougher Rules

HMRC informed that new sanctions under Requirement to Correct will be introduced after 30 September 2018. "You can still make a disclosure after that date but those new terms will not be as good as those currently available," it informed.

Guidance on Tax Avoidance

HMRC introduced guidance to explain tax avoidance, elaborate on tax avoidance schemes and provide instructions on how to get help to settle your tax affairs. HMRC also warned that if a company is involved in a tax avoidance scheme HMRC will fully investigate its tax affairs, and may also:

  • Require company to pay the tax that it is trying to avoid upfront
  • Take legal action
  • Treat the company as a high-risk taxpayer

Sources: HMRC - Disclosure Facility, HMRC - Guidance


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